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OCT 3 5 m J. K. 1IKIDN CARBIDE CORPORATION;P. 0. Box 8361 Engineering, Manufacturing, and Technology Services Central Engineering So. Chas., WV 25303 BUSINESS CONFIDENTIAL September 30, 1986 TO: Hr. J. E. Sanders COPY TO: Hr. L. C. Calvert Mr. S. W. Clark Hr. G. B. Elder Mr. R. W. Engle FROM: C. C. Neely SUBJECT: Final Draft of Recommended C&P Program Phase-Out Use of Asbestos-Containing Materials In Work Place Chemicals and Plastic Group Attached herewith on behalf of the Special Working Group Is a copy of the subject document dated 9/29/B6. It Is a slightly fine-tuned version of the 8/28/86 version which was transmitted to you under my transmittal also dated B/2B/86. The changes that have been made are of a clarifying rather than substantive nature. At this point, we have not made an effort to obtain broad, formal review of the subject program. However, Larry Calvert has discussed It briefly with the Maintenance APM's and Maintenance-Managers. In addition, Stan Clark arranged for Its review by the Safety, Health Advisory Committee (SHAC), and your staff has reviewed It. Feedback Indicates these groups to be supportive of the concept, but some have expressed concern regarding the January 1, 1989 date specified for the discontinuance of the purchase of asbestos-containing materials, believing It to be optimistic. Some of the concern relates to the following: T. CED's ability to revise and reissue the V&P Specifications and the Valve Manual In time to support the deadline. The responsible CED specialists have carefully reviewed this matter and believe that reissuance of these Manuals by July 1, 19B8 Is realistic. This date has not been published, however. UCC 015820 UC-2435 Hr. J. E. Sanders -2- September 30, 1986 2. Belief that field testing of new gasket and packing materials will be required. Such testing will not be necessary since the plan at this time Is to accommodate most of the substitutions by broadening the use of materials already In use, materials such as reinforced Teflon and GRAFOir". This plan has not been broadly disseminated, and we can fully appreciate the reluctance to agree to a purchasing cut-off date for asbestos-containing products without knowing what the substitutes are. We also appreciate that, once this material substitute plan Is known, there will be a natural resistance due to the higher first cost of these substitute materials. 3. Some belief that Installers will need special training to handle the new gasket and packing materials. For reasons cited In (2), we do not believe this requirement will be significant. 4. Perhaps lack of understanding that the January 1, 1989 date Is the cut-off date for the purchase of asbestos-containing materials except as approved by a variance. 5. "Is this really necessary" attitude. The Special Working Group believes that OSHA's recently revised exposure limit of 0.2 fibers per cubic centimeter of air (was previously 2.0 fibers per cubic centimeter) add significant Impetus to Implement the proposed Recommended Program. According to Terry Hanning's September 5, 1986 memorandum (copy attached), labor union representatives do not believe that controlling the exposure limit to this lower level provides adequate protection. The above concerns notwithstanding, the Special Working Group decided to submit the subject Recommended Program to you with the January 1, 1989 date Included since we believe that, with proper communication with the key plant personnel responsible for Its Implementation, along with management support, this date Is realistic and achievable. We are submitting under separate cover a proposed CED Technology Program which Includes request for funds to cover the Important communications aspect of the understanding, acceptance and Implementation process. Please let me know how we can be of further assistance regarding this matter. CCN:mr 43191 Attachment UCC 015821 B/28/B6 DRAFT RECOMMENDED POLICY CHEMICAL AND PLASTICS BUSINESS GROUP (C&P) SUBJECT: USE OF ASBESTOS-CONTAINING HATERIALSC1 >IN THE WORK PLACE PURPOSE/BACKGROUND The Corporate Charter (T.T) contains the following commitment to employees: "To provide working conditions, programs of training and education, and persistent review and appropriate modifi cation of facilities and practices to protect the health and safety of employees." It also contains a social commitment to conduct business "In accordance with all the applicable national and local laws and regulations." As a result of available evidence that airborne asbestos In the occupa tional environment had proven to be carcinogenic In man, all C6P Insulation Standards were revised In 1976 to specify only asbestos-free Insulating materials; and new or replacement Installations of these materials have sub sequently been selected accordingly. Additionally, a Safety/Health Standard designated SH-256 was prepared covering the safe removal and handling (In cludes disposal) of asbestos-containing Insulating material during renova tion and demolition. The requirements of this Standard equal or . exceed those of current applicable government standards. OSKA's rule-making efforts relative to asbestos usage In the work place are mired In controversy. Hearings on the latest EPA proposal which In cludes the phaseout of all asbestos over a ten-year period are now In prog ress. The proposal states: "EPA Is considering banning the manufacture. Importation, and processing of asbestos construction products and asbestos clothing soon after the rule's promulgation with the category'of asbestos friction products banned about five years later, and other asbestos products banned at a later time." Gaskets and packing that contain asbestos are In the category of "other asbestos products" that would apparently be banned after ten years. No peer company that we are aware of has a target date for removal of existing asbestos-containing Insulation, gaskets, or packing; however, one ma^or chemical company has recently discontinued the purchase of asbestos-containing gaskets and packing. A cost analysis of pipe-size gaskets shows that GRAFDIL, probably the most expensive of the acceptable gasket substitute materials. Is, In fact, cost effective when only the cost of mandatory work practices associ ated with the use of asbestos (e.g. wetting for removal or airborne fiber ^"Asbestos-containing materials" Include but are not limited to Insulation, gaskets, packing, welding blankets, and building materials. UCC0I5822 DRAFT 2- - 8/28/86 exposure monitoring during removal, placing In labeled plastic bags after removal, landfill disposal, and record keeping) Is considered. The same conclusion Is drawn relative to valve packing when the additional considerations of Improved servtre -life and seal ability are Included. Consistent with the aforementioned commitments and the economic use of materials, C6P has concluded that positive-actions' relative to asbesto-s-contalnlng materials^) should be taken. POLICY Except as otherwise provided by applicable law, Chemicals and Plastics Business Group will: Continue to phase out the use of asbestos-containing materials: Asbestos-containing Insulation shall be replaced with asbestos-free materials as retired, to maintain structural and functional Integ rity. No asbestos-containing materials shall be purchased after January 1, 1989. CAP approved practices shall be ..employed for the Identification, removal, modification, and/or disposal of asbestos-containing mate rials. Evaluation of asbestos substitute materials shall Include considera tion of health effects as well as suitability for Intended service and cost. A variance approval procedure shall be employed to cover considera tion of uncommon circumstances. Approval must always Include en dorsement of C&P HS&EA management. SCOPE This recommended policy applies to all C&P operated/hosted facilities. Other components of the Corporation will be apprised of Its content. DELEGATION The assignment of duties and authority to carry out the policy defined herein Is delegated as follows: To Central Engineering Department Develop and maintain engineering standards covering: - Identification of asbestos-containing materials; UCC 015823 DRAFT B/28/86 -3- - Removal, modification and/or disposal of asbestos-containing mate rials; and - Use of asbestos-substitute materials. To Site Management Implement policies and practices for the Identification, removal, modification, and disposal of asbestos-containing materials. Use of CEO Standards covering asbestos substitute materials and the communication of service experience with these materials. To Manufacturing Services Monitor use of asbestos-substitute materials and the communication of service experience with these materials. To C&P HS&EA Audit compliance with governmental regulations and CED-developed standards relating to asbestos-containing materials and, where applicable, their substitutes. UCC 015824 C. C. Neely 2073W UNION CARBIDE CORPORATION SPECIALTY products group James J . Polonsky District Sales Her.' , ' P. 0. Box 94637 Cleveland, OH 44101 Ph 1-800-822-4322(0) (713)+852-9468 (H) p.o. box eyjb37. Cleveland. Dho a^idi PHONE: |216) 529-3900 |BOO) B22-A322 . GRAFOrUS Flexible Grathite A Union Carbide Corporation Trademark Product GRAPOIL SEMINAR OUTLINE 1. Solving your packing and gasketing problems. .2 Understanding Asbestos packings or gaskets. 3. Ihe search for an asbestos replacement. 4. Current non-asbestos offerings. 5. Characteristics of Graphite. .6 Hew GRAF0IL is processed from chrystalline graphite. 7. Characteristics of GRAF0H vs . `Graphite 8. Chemical resistance of GRAFUH. 9. Fire testing and fire safety with GRAF0IL. .10 Corrosion protection with GRAFUHJ. .11 ten.cation of GRAF0XL-----Misconceptions ? ? ?? .12 Valves-----Packing Installation procedures and features. 13. Flanges-----Gasketing Installation procedures and features. 14. Gaskets ----- GRAFDH laminate offering and SWS filler. 15. Product Offerings: Packings, gaskets, ribbons, and tapes. The seminar includes demonstrations which assist the participant in his/her understanding of the product and lasts about 90 minutes. NOTE*** - Since several of the demonstraticins require the use of an open flame, your management is requested to provide a cnnrerence room in which these demonstrations may be conducted without violaring the cr safety regulations of your company. UCC 015825 Brand Flexible Graphite Newsletter Number Your Seal of Assurance PG 008 178 SUBJECT: Special Gasketing Techniques With GRAFOIL Flexible Graphite INTRODUCTION GRAFOIL flexible graphite is a resilient form of graphite which has excellent properties as a gasketing material. By itself, GRAFOIL flexible graphite seals about as readily as rubber. It is also fabricated into metal core laminates or into spiral wound gaskets, and significantly improves their characteristics. In general, GftAFOlL gaskets will seal the maximum pressure specified on properly designed, correctly manufactured and suitable maintained equipment. While being flexible and resilient, GRAFOIL flexible graphite is still all graphite. It has no resins, binders or filler materials or other additives that might detract from the chemical inertness and temperature resistance of pure graphite. GRAFOIL gaskets will not cold flow, become brittle, or vulcanize to gasketing surfaces in service. The unique chemical and physical properties of GRAFOIL flexible graphite combine to make it a nearly universal gasketing material especially suitable to high temperature and cryogenic service and|or corrosive environments. GENERAL POINTS TO REMEMBER WHEN GASKETING WITH GRAFOIL FLEXIBLE GRAPHITE 1.) The flange surfaces must be clean,-free of nicks, scratches, burrs, metal fillings, scale or other foreign matter. 2.) Use a proper bolt tightening sequence to ensure a uniform load is applied to the joint (see Figure VI). The use of a torque wrench is advantageous to ensure that a uniform tensile stress is applied to each bolt. 3.) GRAFOIL Grade GHE 316 Stainless Steel Tang Metal Inserted gaskets (Catalog Section G-8817 and G-8819) should not be used between any metal surfaces that are softer than the stainless steel (i.e. aluminum, brass, bronze), or between glass or ceramic surfaces. When GRAFOIL Grade GHE gaskets are used, the metal tangs must be compressed such that the-GRAFOIL begins to seal. Due to the minimum seating stress recommended for these gaskets (i.e. 2500 psi), the metal tangs can-make small indentations in the softer metal of the flange face. The tangs can also create stress concentration points on glass or ceramic surfaces. 4.) GRAFOIL flexible graphite gaskets must be loaded with a net compressive unit load as shown in the Unit Load vs. Leak Pressure Curve, Figure I, and in GRAFOIL Catalog Sections 6-8816 and G-B817. 5.) The initial thicknessof the GRAFOIL gasket must be such that when it is compressed between two mating surfaces, the GRAFOIL is strained sufficiently at all points in the joint to seal the maximum service pressure. If the flange surfaces are scratched, serrated, or warped, the initial gasket thickness must be large enough to completely fill and compensate for their effects when - the joint is made and the gasket is compressed. Of! B.-Oitn UNION CARBIDE CORPORATION On.r.jiini Viephpr,(BOniE2?-i322 In Dtvo. I216I529 3900 TELEX- 810-X2I-0047 UCC 015826 6.) The flatness the flange surfaces is as ssential to good gasketing practice as ,.>e proper gasket Unit load. f gasketed surfaces are perfectly flat under operating conditions, the average unit load is also the minimum unit load. If, for any reason the gasketed surfaces are not flat while in service, the gasket unit load can be less at some point or points than the amount required to seal operating or test pressures. In general, if when the flange faces are brought together (i.e. just touching and under no bolt load), a 0.001" feeler gauge can not be inserted anywhere around the circumference of the joint, then a 1|64 inch (0.015") thick GRAFOIL gasket can always be used. If this criteria can not be met, then the thicker GRAFOIL gasket will be required. IMPORTANT POINTS CONCERNING FLANGE SURFACE FINISH AND "STANDARD" SERRATIONS Under equivalent compressive unit loads, GRAFOIL gaskets will seal where surface finishes range from 5 RMS (root mean square) to 125 RMS. Within that range any RMS finish will seal as well as any other. Flanges ordered with "standard serrations" or a "standard finish" usually have finished surfaces machined in accordance with MSS Standard Practice SP-6 (1) which allows for considerable latitude in finish. The SP-6 Standard refers to AARH finishes or arithmetic average roughness. AARH values are different from RMS valves for any given surface. RMS measurements can be made with stylus tracer instruments, whereas, AARH can not. AARH finishes are evaluated only by "sight and touch" comparisons with standard specimens. The standard serrations may be concentric or spiral. If concentric, there may be up to 32 serrations per inch, and the depth of the serration may range from 0.005" to 0.015". The serration cross-section can range from a radiused "u" cut to a "v" cut. Flange surfaces having the maximum serrations per inch at maximum depth can leave a "saw tooth" surface with little or no flat areas between the serrations. GRAFOIL flexible graphite gaskets are not recommended for use with this type of flange finish. Spiral serrations can range from 20 to 50 per inch in number and from 0.001" to 0.006" in depth. Again, the maximum number of serrations tD maximum groove depth can produce a sharp, "saw-tooth".surface. However, in contrast with concentric serrations, a spiral serration can form a continuous leak path if the gasket material does not deform and ..seal all the way to the bottom of the groove. Consequently, the greater the depth of the spiral serration, the greater the required thickness of the GRAFOIL gasket in order to seal. The required thickness can be calculated in a manner similar to that shown in Case 3. While serrations, in general, do not help GRAFOIL gaskets to seal, GRAFOIL gaskets with their unique physical properties will seal serrations more dependably than most other materials. If a flanged joint is being designed with the intent of using GRAFOIL flexible graphite gaskets, it is recommended that the serrations and surface finish be dimensioned in detail, rather than left to the broad limits permitted by Standard Practice SP-6. (1) Developed and approved by the Manufacturer's Standardization Society of the Valve and fittings Industry, 420 Lexington Avenue, New York, New York 10017. UCC 015827